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The game-changing RMC No. 5-2024

In September, I wrote about a Supreme Court (SC) case covering the sale of satellite communications services by a non-resident corporation, which may potentially have an impact on the taxation of digital services, or what seems (or seemed to be) a gray area in the Philippine taxation. In that case, the SC ruled that the service fees arising from the transmission of satellite signals from a satellite in outer space and Indonesian control center were considered as Philippine-sourced income and thus, subject to withholding taxes in the Philippines. The SC applied a two-tier approach in making its decision: (1) it determined the source of income, and thereafter, (2) the situs of the source. Considering that the income was only earned upon successful delivery of the satellite signals to the Philippine gateways, and that the equipment making up the gateways was situated in the Philippines, the situs for taxation purposes was deemed to be in the Philippines.

The decision was interesting, to say the least, primarily because it appeared to go against the Philippine tax laws on the situs of services – that income from services are only treated as sourced within the Philippines if these are performed locally. Just this month, the Bureau of Internal Revenue (BIR) released Revenue Memorandum Circular (RMC) No. 5-2024 on the basis of the above decision and laid out new cards on the table. Surprisingly and unfortunately, the RMC has not limited the application of the SC decision to transactions similar to satellite services, but has instead used it as reference to determine the taxability of cross-border services — including those that can be physically performed entirely outside the Philippines.

RMC No. 5-2024 provides a list of existing cross-border services which it deems to be “akin” to the transaction covered by the SC case. The list includes consulting services, IT outsourcing, financial services, telecommunications, engineering and construction, education and training, tourism and hospitality, and other similar services where the services are carried out abroad but the results are used, applied, consumed, or executed in the Philippines. Thus, such services are deemed subject to Philippine income tax/withholding tax and 12% VAT. I should mention that VAT was not even touched upon by the SC in the case.

The concept seems to have been anchored on the SC’s decision where it held that for transactions conducted in different jurisdictions, “it becomes imperative to ascertain whether the stages occurring in the Philippines are so integral to the overall transaction that the business activity would not have been accomplished without them.” On this basis, the RMC focuses on the “benefits-received” theory in determining whether the income is Philippine-sourced, where the place of utilization/consumption of the output or result now appears to be crucial in determining the taxability of a transaction. For this purpose, the RMC seems to consider the utilization or consumption as the economic activity that generates the income, thus giving rise to Philippine taxing rights on the entire amount of income without any clear separation or attribution of revenue for each country.

However, our tax law is not ambiguous on the taxation of services, especially those which arise from physical labor. Under Sections 42 and 108 of the Tax Code, it is very clear that service fees are only considered as sourced within the Philippines and subject to income tax and VAT if the services are performed within the country. Philippine tax literature is likewise replete with court decisions and even BIR rulings upholding that income arising from services rendered outside the Philippines are not subject to Philippine tax. The SC itself has repeatedly held that administrative rules must not go beyond the law that it seeks to implement. I am, thus, very curious on how the RMC has arrived at what seems to be a categorical imposition of Philippine tax on offshore services rendered to Philippine residents.

Interestingly, the RMC does not mention how it will be applied in instances where the counterparty is a resident of a tax treaty country, unlike the SC decision which takes cognizance of tax treaties (but were not applied since the case involved a non-resident entity from Bermuda, a country with no existing tax treaty with the Philippines). Tax treaties are bilateral tax agreements between countries. Generally, if certain conditions under the treaty are met, income derived by the foreign income earner from Philippine sources would be exempt from Philippine tax. Since tax treaties are international agreements which have the force and effect of law, I believe that even though the RMC is silent, residents of treaty countries may be protected from the RMC’s ramifications if there is applicable treaty relief. Applying the RMC, however, affected foreign taxpayers will be subject to similar administrative requirements as other taxpayers seeking tax treaty relief.

The RMC likewise does not cover the tax implications if the situation were reversed — how do we apply it to export services by Philippine entities? For income tax purposes, it may not have a significant impact on domestic corporations which are taxed based on worldwide income. However, how would it affect resident foreign corporations which are only taxed on Philippine-sourced income? By applying the benefits-received principle in the RMC, does it mean that if a branch of a foreign corporation were to render services in the Philippines for a foreign customer, the situs of the services would likewise be in the foreign country where the customer is and therefore the revenue is not subject to Philippine tax?  Similarly for VAT, can we consider the mere consumption of the output/product outside the Philippines as a basis for exemption?   

Previously, the SC decision’s potential impact was anticipated to possibly affect the taxation of foreign digital services consumed in the Philippines. Before the issuance of the RMC, digital services were considered a gap in our system, which pushed legislators to draft laws to address such shortcomings. With the RMC, it seems the enactment of a formal law taxing digital services, which Congress has been working on for the past few years, has become moot. Considering, however, that the RMC did not stem from a new law, there is an increasing concern among taxpayers that the rules provided would be applied retrospectively by the BIR, particularly in ongoing tax audits.

The issuance of this RMC has not only touched upon the digital realm, but has also trod outside Philippine waters. Non-residents who are currently providing or those planning to provide services to Philippine customers must take note of this, even if they have no physical presence in the Philippines. While we await (and hope for) further clarification, local income payors, as the agents who are primarily liable to withhold taxes on their payments to non-residents, must also now carefully review their transactions to ensure that they comply with the new requirements. The RMC is clear in its intention — it wants to change the rules of the game.

The views or opinions expressed in this article are solely those of the author and do not necessarily represent those of Isla Lipana & Co. The content is for general information purposes only, and should not be used as a substitute for specific advice.

 

Olivia Erika Susa is a senior manager at the Tax Services department of Isla Lipana & Co., the Philippine member firm of PricewaterhouseCoopers global network.

olivia.erika.susa@pwc.com

Marcos pushes easing Charter limits but bucks foreign ownership of land

PRESIDENT Ferdinand R. Marcos, Jr. wants the power to grant and approve tax incentives to be returned to investment promotion agencies, a lawmaker said. — PHILIPPINE STAR/KRIZ JOHN ROSALES

PHILIPPINE President Ferdinand R. Marcos, Jr. on Tuesday backed moves to amend economic provisions of the country’s 36-year-old Constitution, which he said was “not written for a globalized world.”

The President, however, was critical of proposals to allow full foreign ownership of land, media and power generation.

There are strategic areas that “we cannot allow to be influenced by foreign entities, be it a corporation or another country,” he told GMA News. “That’s what we have to decide, where we draw the line and how much.”

Mr. Marcos said allowing foreigners to fully own land could drive property prices up, leaving citizens unable to pay real estate tax. “I don’t think I agree with that.”

The 1987 Constitution limits land ownership to Filipino citizens and corporations that are at least 60% Filipino-owned.

Analysts urged the government to study whether pursuing all-out economic liberalization would benefit the country.

Think tank IBON Foundation urged the government to look at how developed countries including the United States have pursued protectionist policies in recent years to expand their industrial base.

“Trade protectionism is more dominant than liberalization among new state interventions today, with the US implementing the most protectionist measures in the past 15 years,” IBON Executive Director Jose Enrique “Sonny” A. Africa said in a Facebook Messenger chat. “Investment restrictions and regulations have also unambiguously been on the rise over that same period.”

He said protectionism, which has been pursued by industrial powers to develop their semiconductors, renewable energy and other critical technologies and infrastructure, is even more pressing for the Philippines.

For example, manufacturing is 100% open to foreigners and there’s about $17 billion in foreign investment in the domestic sector today, “and yet Philippine manufacturing has fallen to its smallest (17.6%) since 1949, and its employment share to the smallest (7.3%) on record,” Mr. Africa said.

“There’s been increasing skepticism that corporate-driven globalization policies really benefit the majority and not just big businesses,” Joseph F. Purugganan, convenor of Trade Justice Pilipinas, said via Messenger chat.

“Ensuring that benefits of economic development redound to the working classes — farmers, fishers, workers, indigenous peoples — should be the framework.”

But Leonardo A. Lanzona, who teaches economics at the Ateneo de Manila University, said the Philippines needs foreign direct investments not only to increase capital in the face of mounting debt “but more importantly to be part of the evolving reconfiguration of the global value chain after a coronavirus pandemic.”

“Participating in global value chains exposes the country to new technologies that are crucial in reaching upper middle-income status by 2025,” he said via Messenger chat.

“While we can learn and adopt new technologies in our own way, participation in the global value chain is a short-cut or detour for making this a reality quickly.”

‘PEOPLE’S INITIATIVE’
A survey conducted by Octa Research on Dec. 10 to 14 showed that amending the 1987 Constitution was not a major concern of the public, with only 1% of adult Filipinos thinking Charter change (“Cha-cha”) was urgent.

Meanwhile, a people’s initiative has obtained enough signatures to start changes to the 1987 Constitution, Albay Rep. Jose Ma. Clemente S. Salceda told reporters. “As of last night, we’ve reached the 12.1% threshold.”

The Constitution may be amended either through a constitutional convention composed of delegates, by Congress sitting as a constituent assembly or through a people’s initiative.

Under the law, the signatures must account for at least 12% of voters nationwide and 3% of voters in each legislative district. The Supreme Court rejected a similar campaign in 1997 in the absence of an enabling law.

Any proposed amendments or revisions must be ratified by majority of Filipinos in a plebiscite.

Philippine senators on Tuesday opposed a proposal for both chambers of Congress to vote jointly to change the Constitution, saying senators could not cast meaningful votes against more than 300 congressmen.

“If this people’s initiative prospers, further changes in the Constitution will open the floodgates to a wave of amendments and revisions that will erode the nation as we know it,” according to a statement signed by all senators and read by Senate President Juan Miguel F. Zubiri in plenary.

Last week, Mr. Zubiri said President Ferdinand R. Marcos, Jr. had asked the upper chamber to lead the review of the Constitution’s economic provisions, saying the President thought a people’s initiative push was too divisive.

The Senate president said a joint voting on charter change would “destabilize the system of checks and balances.”

Senator Joseph Victor G. Ejercito on Wednesday warned of a constitutional crisis, while Senator Juan Edgardo “Sonny” M. Angara said “it’s clear that the people’s initiative is not a genuine people’s initiative.”

But Mr. Salceda said the people have spoken and the Senate should respect their decision, amid allegations that voters were paid in exchange for their signatures. He said about 20% of voters in his district signed the petition.

The President on Tuesday said he expects the Commission on Elections to verify if voters had been paid to support the people’s initiative. Kyle Aristophere T. Atienza and B.M.D. Cruz

Marcos gives jeepney operators three more months to consolidate

PHILIPPINE STAR/WALTER BOLLOZOS

PRESIDENT Ferdinand R. Marcos, Jr. has approved the Transportation department’s proposal to give jeepney and other public utility vehicle (PUV) operators three more months to consolidate under the state’s modernization plan.

The deadline was extended to April 30 from Jan. 31, the presidential palace said in a statement on Wednesday.

“This extension is to give an opportunity to those who expressed the intention to consolidate but did not make the previous cut-off,” Presidential Communications Office chief Cheloy Velicaria-Garafil said.

The House of Representatives transportation committee on Wednesday drafted a resolution asking the President to extend the deadline to protect stakeholders and commuters.

The lawmakers said the intention of the modernization program is beyond question and the plan is long overdue.

But “the needed reforms must be done in accordance with the law and due process to ensure the protection of the affected stakeholders and the riding public in general,” according to a copy of the draft resolution. It did not specify a new deadline.

“The very essence of the resolution is to reconsider the implementation of a consolidation deadline,” Santa Rosa City Rep. Dan S. Fernandez, who moved for the filing of the resolution, told a hearing on Wednesday.

Unconsolidated PUVs originally had until Jan. 31 to operate, or a month after the year-end consolidation deadline.

The committee approved Mr. Fernandez’s motion to ask the President and Transportation department to consider extending the deadline “until the government can come up with a concrete plan to address the major issues in the implementation of the program.”

More than 300 public utility jeepney (PUJ) routes and 76 UV Express routes in Metro Manila alone have not been consolidated, according to the Land Transportation Franchising and Regulatory Board (LTFRB) website.

About 38,000 jeepney drivers could lose their jobs next month when the PUV modernization program takes effect, LTFRB Chairman Teofilo E. Guadiz III said on Jan. 10.

“If we’re not allowed to operate by Feb. 1, what will we feed our families?” Lito Andal, who heads a group of jeepney drivers based in central Luzon, told the House hearing in Filipino. “This is the only job that we know.”

Transport group Pinagkaisang Samahan ng mga Tsuper at Operators Nationwide (PISTON) urged the government to focus on supporting local manufacturers of modern jeepneys if it really wants to modernize public transportation.

The modernization plan would likely lead to fare increases, PISTON President Mody T. Floranda told congressmen. 

Think tank IBON Foundation estimates that PUV fares could increase by as much as P50 in the next five years if modernization takes place. — Kyle Aristophere T. Atienza and Beatriz Marie D. Cruz

Philippines told to boost maritime ties with ASEAN

PHILIPPINE COAST GUARD FILE PHOTO

THE PHILIPPINE Coast Guard (PCG) should also boost maritime cooperation with other Southeast Asian nations other than Vietnam amid the slow development in the push for a code of conduct (CoC) in the South China Sea, an analyst said.

A possible cooperation deal between the Philippine Coast Guard (PCG) and its Vietnamese counterpart, which they have been working on since 2018 and is expected to be sealed this month, could be an “informal model” for the proposed South China Sea code of conduct, said Joshua Bernard B. Espeña, who teaches international relations at the Polytechnic University of the Philippines.

“It is an opportunity to provide an informal model for a yet to be concluded ASEAN-China Code of Conduct for parties in the South China Sea,” he said in a Facebook Messenger chat.

Mr. Espeña said the “lack of operational models for a legally binding instrument” has delayed the approval of the code of conduct.

The Philippine Coast Guard on Tuesday gave a “comprehensive briefing” to Vietnamese officials, including Vietnam’s Standing Deputy Minister of Foreign Affairs Nguyen Minh Vu and Ambassador to the Philippines Lai Thai Binh, on Manila’s maritime security operations in the South China Sea.

The two countries also sought to advance a memorandum of understanding (MOU) between the PCG and its Vietnamese counterpart, which they have been working on since 2018.

The proposed cooperation deal is expected to be sealed during President Ferdinand R. Marcos, Jr.’s visit to Vietnam next week. Mr. Marcos, 66, said during his visit to the United States last year his government was seeking to set up a separate code of conduct with Vietnam and Malaysia.

The Philippine leader cited the slow progress of the code between China and ASEAN members.

“Pushing for another memorandum of understanding with Malaysia, for instance, can provide the Philippines a calibrated diplomatic shot to make regional stability one step closer compared with the past 30 years,” Mr. Espeña said.

“If so, Manila should work on these memos rather than grand arrangements like mini-CoCs to operationalize,” he said.  “The best approach is the one that works. We must try another approach until something works.”

After the Philippines’ push for a separate code of conduct, China warned that any departure from the Declaration on Conduct of the Parties in the South China Sea, which provided the framework for the regional code, would be void.

“The key is pragmatism based on national interests that work on the ground,” Mr. Espeña said.

The Philippines, Vietnam, Brunei, and Malaysia — all ASEAN members — as well as Taiwan and China hold overlapping claims over some features in the South China Sea, which Beijing claims almost in its entirety.

Vietnam was said to be the “last man standing” in the South China Sea conundrum when the Philippines pivoted to China during the previous administration.

Hanoi conducted major expansion activities such as dredging and landfill work at most of its South China Sea outposts in 2022.

Mr. Espeña said despite rebuking the Philippines last year for putting buoys in the Spratly Islands, Vietnam has pursued closer ties with Manila.

“In other words, Vietnam deemed it better to work synchronously with the Philippines in this area than separately,” he said.

Mr. Marcos is expected to sign a five-year rice deal with his Vietnamese counterpart during his visit to the fast-rising global manufacturing hub.

Mr. Espeña said the Philippines should complement its fiery stance on its sea dispute with China with hard-knock capabilities on the ground.

“This point is necessary because Hanoi may not find Manila reliable soon if it is all bravado in statements but disconnected to the ground,” he said.

“This commitment includes sustaining Filipino operations with a logistically sophisticated network and an interoperable maritime force that can move, shoot, and communicate competently.” — Kyle Aristophere T. Atienza

Filipino IDF soldier dies in Gaza blast

PHILIPPINE STAR/EDD GUMBAN

By John Victor D. Ordoñez, Reporter

A FILIPINO soldier was among the 21 Israel Defence Force (IDF) troops who died in Monday’s blast in Central Gaza, the Embassy of Israel in the Philippines confirmed on Wednesday.

In a statement, the embassy said Sergeant First Class Reserve Cydrick Garin was killed as a result of the massive explosion caused by a rocket attack launched by Hamas militants.

“The Embassy of Israel in the Philippines is currently facilitating the travel of Sgt. Garin’s father to Israel,” it said.

“Israel shares the profound grief of Sgt. Garin’s family and the Filipino community,” the Israel embassy added.

At least four other Filipinos, all caregivers, have died since the conflict turned violent last year.

Israel launched waves of airstrikes in Gaza in retaliation after Hamas militants backed by waves of rockets stormed from the blockaded Gaza Strip into nearby Israeli towns on Oct. 7, last year.

Last December 12, the Philippines joined 152 countries in voting “yes” to a United Nations General Assembly (UNGA) resolution calling for a ceasefire and the unconditional release of all hostages.

Israel and the United States were among the 10 countries that voted against the resolution, with 23 states abstaining.

In a report by the Hamas-run Gaza health ministry on Jan. 21, it was revealed that more than 25,000 have died in the war.

UN Special Rapporteur for Freedom of Opinion and Expression visits DoJ

VISITING United Nations Special Rapporteur on Freedom of Opinion and Expression Irene Khan emerges from the Department of Justice main building in Manila with Philippine Justice Undersecretary Raul Vasquez after a dialogue on promoting transparency, accountability, and the pursuit of justice and human rights in the country on Wednesday. — PHILIPPINE STAR/ERNIE PENAREDONDO

UNITED NATIONS (UN) Special Rapporteur for Freedom of Opinion and Expression Irene Khan and Department of Justice (DoJ) officials held a dialogue on Wednesday focused on best practices and expertise on policies and reforms to uphold freedom of opinion in the country.

In a statement released after the meeting, Justice Undersecretary Raul T. Vasquez vowed to pursue more engagements and partnerships with international stakeholders and the UN on the promotion of basic human rights in the Philippines.

He said the meeting “strengthened our commitment to transparency, accountability, and the pursuit of justice and human rights.”

“We remain dedicated to implementing meaningful reforms and upholding the highest standards in our judicial framework,” he added.

Ms. Khan is set to meet with Philippine foreign affairs officials today, Thursday, ahead of talks with civil society and human rights experts during her 10-day visit in the country. — John Victor D. Ordoñez

DFA: ASEAN pacts a priority

OFFICIALGAZETTE.GOV.PH

FULFILLING the Philippines’ existing economic cooperation agreements with member-states of the Association of Southeast Asian Nations (ASEAN) stands as a priority, the Department of Foreign Affairs (DFA) underscored on Wednesday.

“We will focus on ongoing agreements since no (new) initiatives have been raised yet,” Foreign Affairs Assistant Secretary Daniel R. Espiritu told a news briefing, ahead of DFA Secretary Enrique A. Manalo’s scheduled participation in the ASEAN Foreign Ministers’ retreat on Jan. 28-29 in Luang Prabang, Laos.

Last November, the Bangko Sentral ng Pilipinas signed a cooperation pact with other central banks in ASEAN to bolster collaboration on payment connectivity. “The Philippines’ plate is still full of (economic) agreements in ASEAN,” Mr. Espiritu said.

Moreover, Mr. Manalo is also set to attend the ASEAN-EU (European Union) ministerial meetings on Feb. 2 in Brussels, Belgium.

In a working paper last October, the International Monetary Fund reported that pushing for more free trade agreements in ASEAN, eliminating non-tariff barriers, strengthening global value chains, and boosting digitalization could boost Philippine economic growth. — John Victor D. Ordoñez

Jakarta sea lanes can guide PHL

FRANCISTOLENTINO.PH

A SENATOR has suggested that Congress pattern after Indonesia’s established archipelagic sea lanes the crafting of the Philippines’ own sea lanes, amid rising tension with China over disputed areas of the South China Sea that are closest to Manila.

“It will really guide the committee in approaching all of the issues concerned considering that Indonesia is the only country with the sea lanes coming from the group of 22 countries,” Senator Francis N. Tolentino said on Wednesday.

As head of the Senate Special Committee on Maritime and Admiralty, Mr. Tolentino asked the Department of Justice (DoJ) during the panel’s hearing to look into the Indonesian law that established its sea lanes in 2008.

The Senate is set to debate in plenary a bill seeking to set Philippine maritime zones and territories extending to disputed areas in the South China Sea.

Among the key provisions of the Indonesian law that will be looked into is the measurement of its archipelagic baselines, the longest of which extends about 124 nautical miles.

Meanwhile, the Philippines has filed four diplomatic protests against China over incursions in the South China Sea in January, Philippine Foreign Affairs spokesperson Ma. Teresita C. Daza said in a WhatsApp Message.

She said the government had filed 66 diplomatic protests last year.

Tensions between the Philippines and China have worsened after the Chinese Coast Guard fired water cannons to block Manila’s delivery of food and other supplies to Filipino troops stationed at a World War II-era warship intentionally grounded on a shoal to stake the Philippines’ claim on the waterway. — John Victor D. Ordoñez

NLEX opens new Bulacan exit

NLEX CORP. said on Wednesday that it has completed the widening of the North Luzon Expressway’s Meycauayan Northbound Exit Ramp and opened a new exit for class 1 vehicles leading to F. Raymundo Street in Meycauayan City, Bulacan.

In a statement, NLEX said the widening project has paved the way for a new dedicated lane for Malhacan-bound vehicles.  The leftmost and middle lanes will be assigned for vehicles going to Iba/Camalig.

Meanwhile, NLEX said that the new F. Raymundo Exit is expected to cater to class 2 and 3 vehicles once the city government of Meycauayan completes the widening and upgrading works at the corner of F. Raymundo and Antonio Streets.

“We are very happy to announce the opening of these two projects that will help decongest the Meycauayan Northbound,” NLEX Corp. President and General Manager J. Luigi Bautista said.

The tollway company, a unit of Metro Pacific Tollways Corp., said that the new exit will reduce volume at the Meycauayan interchange as it will serve as an alternate route for those bound for Iba/Camalig, Metrogate, Lias, Lambakin, and Pantoc.

Under a traffic management cooperation agreement, NLEX and the City of Meycauayan will team up in manning the area with traffic personnel and marshals. — Sheldeen Joy Talavera

Anti-child labor projects unveiled

PHILSTAR

COTABATO CITY — Two anti-child labor projects have been launched by the Bangsamoro region’s Ministry of Social Services and Development, which has joined the bloc of local and foreign entities coming together to address the problem here and in the six provinces of the Bangsamoro Autonomous Region in Muslim Mindanao (BARMM).

Jidday Buat Lucman, senior information officer of the ministry, identified the two key projects as the Key Actions towards Lifting Young Bangsamoro thru Empowerment or KALYE, and the Support to End Child Labor or SECL.

KALYE is designed to provide daily meals for former child laborers for four months, along with essential psycho-social interventions, while SECL shall provide rescued child laborers with education and financial support needed to hasten their rehabilitation.

Both designed by child welfare and rights experts, these projects were launched last Tuesday at the People’s Palace, here, by Minister Raisa H. Jajurie. — John Felix M. Unson

Gutsy Medvedev outlasts Hurkacz

DANIIL MEDVEDEV — REUTERS

Qualifier Yastremska beats Noskova to book semis spot

MELBOURNE — Third seed Daniil Medvedev was forced to dig deep into his reserves to outlast Hubert Hurkacz 7-6(4) 2-6 6-3 5-7 6-4 in an epic quarterfinal on Wednesday and reach the last four of the Australian Open for third time.

Dayana Yastremska beat Czech Linda Noskova 6-3 6-4 on Wednesday to book a semifinal spot at the Australian Open, becoming the first women’s qualifier to reach the last four in Melbourne since the 1978 tournament.

The Russian, twice a losing finalist at Melbourne Park, went toe-to-toe with the big Pole for almost four energy-sapping hours on Rod Laver Arena before finally setting up a clash with Carlos Alcaraz or Alexander Zverev.

Ninth seed Mr. Hurkacz, who was playing in only his second Grand Slam quarterfinal but had a winning career record against Mr. Medvedev, twice came from a set down and made the Russian work hard for every single point.

Former US Open champion Mr. Medvedev, who saved 10 of the 15 break points he faced over the contest, grizzled and moaned his way around the court but finally secured a place in his eighth Grand Slam semifinal with the most delicate of drop shots.

“I’m so destroyed right now,” said Mr. Medvedev, who played a five-set marathon into the early hours of the morning in the second round. “In the fourth set … I’m like ‘I just have to try my best to do whatever I can and let’s see, if I lose, I lose and go home’. I’m happy that I managed to win like this. I really liked the match point.”

The players look well matched from the opening set, both solid on their first serves but looking fragile on their second and claiming a break apiece.

Mr. Medvedev mixed it up a bit by coming into the net to show off his volleying skills as he clinched the tiebreak but Mr. Hurkacz came out firing in the second set.

The Pole was rewarded with a slew of winners and an early break, while Mr. Medvedev needed to show his mettle through four deuces to avoid going 3-0 down.

Mr. Hurkacz was now getting a look at Mr. Medvedev’s serve in every return game and did get his second break for 5-2 before holding to love to level up the contest.

It was Mr. Medvedev’s turn to make a hot start to the third set, the Russian racing out to a 3-0 lead on the back of a single break handed to him when the Pole double faulted.

Mr. Hurkacz held to avoid giving up the set on a third break of serve but Medvedev was now banging down a few winners of his own and went two-one up with his eighth ace.

The 27-year-old again broke to start the fourth set but Mr. Hurkacz was still giving as good as he got through some high quality passages of play and got back on terms at 4-4.

The Pole pounced to break Mr. Medvedev again to square up the match and took the momentum into the decider when the Russian would surely start to feel the effects of his second round marathon.

Mr. Medvedev conserved energy and bided his time until an opportunity presented itself, pouncing when a brilliant backhand return gave him a look at 3-3 and driving home the advantage to snatch the crucial break.

The Russian held with difficulty, particularly after a remarkable Mr. Hurkacz save to win one point, but made no mistake when serving for the win, striking a balletic pose and blowing kisses to his team after converting his second match point.

YASTREMSKA
Battling in 30 degrees Celsius (86 degrees Fahrenheit) heat, the Ukrainian’s powerful forehand eventually overcame the 19-year-old Czech, who was the youngest player left in the draw.

Ms. Yastremska, 23, follows in the footsteps of Christine Dorey, the last qualifier to reach the Melbourne Park semis 45 years ago.

The players traded breaks early in the first set, but it was Ms. Yastremska who took the lead in the eighth game when Noskova netted a backhand.

Despite failing to get nearly half her first serves in, the Ukrainian kept the pressure on with a string of forehand winners throughout the match.

Ms. Noskova failed to capitalise on a break point when she was down 5-3 and Yastremska wrapped up the first set in 36 minutes with another well-targeted forehand. Both players went off court after the first set, escaping the heat, and Ms. Noskova had a long chat with her coach on her return.

The players were on level pegging throughout the second set until the seventh game when Ms. Yastremska locked it up on her third break point with a backhand winner that left Ms. Noskova stranded on the far side of the court.

She closed out the match on serve when Ms. Noskova’s backhand return hit the net, ending the Czech’s bid for her first tour singles title and becoming the first qualifier to reach this stage of a Grand Slam since Emma Raducanu won the US Open in 2021.

The world number 93, who has already beaten two Grand Slam champions during the tournament, next faces either 12th seed Zheng Qinwen of China or Russian world number 75 Anna Kalinskaya, who play their quarterfinal later on Wednesday. — Reuters

Strong Group Athletics cruises to quarterfinals in Dubai

KEVIN QUIAMBAO — FACEBOOK.COM/STRONGGROUPATHL

UNSTOPPABLE Strong Group Athletics cruised to its fourth straight win in as many games, rolling past Beirut with a 95-73 blowout to clinch a quarterfinal ticket in the 33rd Dubai International Basketball Championship yesterday at the Al Nasr Club.

Kevin Quiambao, the team’s leading scorer, once again flashed his brilliance with 20 points on four triples laced by four rebounds and a steal as he continued to make heads turn in Dubai.

It’s the fourth straight double-digit performance for the UAAP Most Valuable Player from De La Salle University, who lured interest from United Arab Emirates basketball officials to reinforce its national team in the future.

McKenzie Moore backstopped Mr. Quiambao with 19 points, five rebounds and eight assists as Jordan Heading added 15 more for coach Charles Tiu’s charges.

Birthday boy JD Cagulangan threw in 12 points and six assists with Dwight Howard collaring a near 11-9 double-double after his 32-point eruption against another Lebanese team in Homenetmen.

Mr. Quiambao fired nine of his total output in the first quarter, highlighted by a putback to give Strong Group an early 32-20 advantage. The team owned by Jacob and Frank Lao was never threatened from there on for another commanding victory.

At 4-0, Strong Group — with a winning margin average of 17.3 points — warmed up for a gigantic duel against fellow unbeaten Al Ahly Tri Sports Club of Libya Thursday for the top seeding in Group B entering the knockout quarterfinals.

The Libyan ball club subdued a strong challenge from Syria’s Al Wahda, 93-84, to also go 4-0.

Meanwhile, reigning champion Al Riyadi — the tormentor of Strong Group in the quarterfinals last edition — also stayed unbeaten in Group A with a 4-0 slate after clobbering compatriot squad Sagesse, 96-76. — John Bryan Ulanday